UK Modern Slavery Statement

This statement is made pursuant to the requirements of Section 54 of the Modern Slavery Act 2015 on behalf of The Bradford Exchange, Ltd., UK Branch. The following statement reflects the activities and efforts undertaken to achieve this during the year ending 31st December 2016.

The Bradford Exchange, Ltd., UK Branch, is part of The Bradford Group of companies. Since the early 1970s, The Bradford Exchange, Ltd. (“Bradford”) has been recognised as the premiere source for a vast array of unique limited-edition collectables and fine gifts that offer an exceptionally high level of artistry and innovation.

Bradford’s business includes the sale of merchandise, the sourcing of merchandise (through third party vendors under contract to an affiliated company), and the operation of e-commerce websites. The wide range of products sold by our company necessarily has supply chains that are highly varied in terms of both types of supply and their locations. Each of these supply chains includes potential risks associated with possible labour-related issues.

To mitigate the risk of slavery and human trafficking in our supply chains, Bradford’s sourcing affiliate maintains a Code of Conduct for Manufacturers (the “Code of Conduct”). The Code of Conduct is consistent with the conventions of the International Labor Organization.

The Code of Conduct is designed to help address working conditions, including the use of slavery and human trafficking. Our Code of Conduct includes specific provisions on forced labour that prohibit the use of forced labour – whether prison, indentured, bonded, or otherwise – in the production of Bradford products. Our Code of Conduct also includes a provision prohibiting child labour. Our Code of Conduct also prohibits the use of harassment or abuse against a vendor’s employees, including physical, sexual, psychological, or verbal harassment or abuse.

Our vendors also agree that they will comply with all applicable laws and regulations concerning the manufacture of Bradford products (which would necessarily include compliance with laws regarding forced labour, human trafficking, and slavery).

Periodic guidance on the requirements of the Code of Conduct, including in-person training, is provided to relevant employees and staff of our vendors or trade partners. The company also periodically audits labour conditions in some of the facilities in the supply chain for Bradford products. These on-site audits are conducted by our staff, by specialised third parties engaged by Bradford for the purpose, and by or on behalf of some of our licensors.

The Board of Directors of The Bradford Exchange, Ltd., UK Branch, have viewed this statement and approved it.